Last updated: 4 October 2026
This Privacy Policy explains how Scott Daniel Feeney trading as Recirc.AI (ABN 92 721 361 463) (“Recirc.AI”, “we”, “our” or “us”) collects, uses, discloses and protects personal information. It applies to our website, our dealings with prospective and existing clients, and the information we handle when we provide services to our clients.
Recirc.AI provides a managed job-capture service for Australian HVAC businesses. The service helps our clients capture, follow up, organise and re-engage customer enquiries, and passes enquiries that are ready for action to the client’s own team.
1. Our commitment to privacy
We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy is intended to explain our practices in a clear and open way, as APP 1 requires.
2. What personal information we collect
The personal information we collect depends on how you deal with us. It may include:
- Contact and identity details: your name, business name, job title, email address, phone number and business or postal address.
- Business details: your ABN, legal business name, trading name, services, locations, operating hours and other information needed to set up and run our services for your business.
- Website forms and enquiries: what you tell us when you fill in a form on our website, request information or ask us to call you.
- Calls: phone numbers, call times and call details, and recordings of calls where you have been told the call may be recorded.
- SMS: phone numbers, the content of text messages sent and received, delivery details and whether you have opted out.
- Email: email addresses, the content of emails, and whether an email was delivered or opened or a link was clicked.
- Payment details: billing name, billing contact details and transaction records. Card payments are processed by Stripe. We do not store your full card number.
- Technical information: IP address, browser and device type, the pages you visit on our website and how you arrived there, collected through cookies and similar technology (see section 8).
We only collect personal information that is reasonably necessary for our functions and activities. You can deal with us anonymously or using a pseudonym when making a general enquiry, but we may not be able to help you or provide our services if you do.
We do not intend to collect sensitive information (such as health information). If sensitive information is included in a message or call, we will only handle it as the law allows.
3. How we collect personal information
We collect personal information:
- directly from you, through our website forms, phone calls, SMS, email and meetings;
- from our clients, when they give us details of their customers and enquirers so that we can provide our services to them;
- when someone contacts one of our clients through a phone number, form or message channel that we manage for that client;
- from our service providers, including Stripe when you make a payment; and
- automatically, through cookies and similar technology when you use our website.
If we receive personal information we did not ask for, we will check whether we could have collected it lawfully. If not, we will destroy or de-identify it where it is lawful and reasonable to do so.
4. How we use personal information
We use personal information to:
- respond to enquiries and arrange calls with prospective clients;
- prepare, sign and manage client agreements and order forms;
- set up, provide, support and maintain our services for clients;
- handle enquiries and follow-up messages on behalf of our clients, as instructed by them;
- process payments, issue tax invoices and manage billing;
- send service and account messages to clients;
- send marketing messages about Recirc.AI where you have consented or where the law otherwise allows;
- maintain the security of our systems and prevent misuse;
- improve our website and services; and
- meet our legal, tax and record-keeping obligations and enforce our agreements.
We will not use or disclose personal information for a purpose other than the one it was collected for unless you have consented, you would reasonably expect it, or the law requires or allows it.
5. Information we handle for our clients
When we provide our services to a client, we handle personal information about that client’s customers and enquirers (for example, a person who calls, texts or fills in a form for an HVAC business we work with). We handle that information on behalf of our client, for the purpose of providing our services to them, and in line with our client agreement.
Our clients are responsible for having a lawful basis, including any consent required, for customer information they give us, and for their own privacy practices. If you are a customer of one of our clients and have a question about how your information is handled, you can contact that business directly or contact us using the details below.
Some of the tools we use to provide our services process the content of calls, messages and forms using software, to help capture and organise enquiry details for our clients. Our clients’ teams make the decisions about their customers.
6. Marketing, SMS and calls
We only send commercial electronic messages in line with the Spam Act 2003 (Cth). Every marketing message from us identifies Recirc.AI and includes a way to opt out.
- You can opt out of SMS at any time by replying STOP.
- You can opt out of marketing email at any time by using the unsubscribe link.
We action opt-outs promptly and keep a record of them so that we do not contact you again. Where we make marketing calls, we follow the Do Not Call Register Act 2006 (Cth). We may still contact existing clients about the services they receive from us.
Standard carrier message and data rates may apply. We do not sell or rent personal information, and we do not give phone numbers or email addresses to third parties for their own marketing.
7. Who we disclose personal information to
We do not sell personal information. We disclose it only as needed, to:
- third-party service providers who help us run our business and deliver our services, such as software, telecommunications, SMS and email delivery, website hosting, data storage and analytics providers;
- Stripe, our payment processor, which processes card payments and related information in line with its own privacy policy (stripe.com/au/privacy);
- our clients, where we handle information on their behalf (for example, passing a customer’s enquiry details to the HVAC business they contacted);
- our professional advisers, such as accountants and lawyers; and
- government bodies, regulators or others where the law requires or allows it, or to establish, exercise or defend a legal claim.
We require our service providers to use personal information only to provide their services to us, and we take reasonable steps to choose providers with appropriate security and confidentiality practices.
8. Cookies and analytics
Our website uses cookies and similar technology. Some are needed for the website to work. Others help us understand how the website is used and measure the results of our own marketing, including analytics and advertising measurement tools provided by third parties. These tools may collect information such as your IP address, device and browser type, and the pages you visit.
You can block or delete cookies through your browser settings, and you can adjust ad personalisation in your account settings with the relevant platforms. If you block cookies, some parts of the website may not work properly.
9. Overseas disclosure
Some of our service providers, including Stripe, store or process personal information outside Australia. This may include the United States and other countries where those providers or their data centres are located.
Before we disclose personal information overseas, we take reasonable steps to make sure the recipient handles it in a way that is consistent with the Australian Privacy Principles, as APP 8 requires.
10. How we protect personal information
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include using reputable service providers, access controls and secure payment processing. No method of storing or sending information over the internet is completely secure.
If we become aware of a data breach that is likely to result in serious harm, we will assess it and notify affected individuals and the Office of the Australian Information Commissioner where the Notifiable Data Breaches scheme requires it.
11. How long we keep personal information
We keep financial records for at least 5 years as required by law, client records for up to 7 years after our services end, and other personal information only for as long as we need it, after which we securely delete or de-identify it.
In practice:
- Financial and tax records are kept for at least 5 years, as required by the Australian Taxation Office.
- Client agreements and client records are kept for up to 7 years after our services end.
- Marketing consent records are kept while we are sending messages, plus a reasonable period afterwards. Opt-out records are kept permanently so that we do not contact you again.
- Information about prospects and enquiries is deleted or de-identified once we no longer need it, generally within about 2 years.
- Call recordings and text messages we handle for a client are managed as our client agreement sets out. Otherwise, they are deleted after the client stops using our services.
12. Access and correction
You can ask for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 15.
We will respond within a reasonable period. We may need to confirm your identity first. There is normally no charge for making a request. If we refuse access or correction, we will tell you why in writing (unless it would be unreasonable to do so) and explain how you can complain.
If your request is about information we hold on behalf of one of our clients, we may refer it to that client or work with them to respond.
13. Complaints
If you think we have breached the Australian Privacy Principles or mishandled your personal information, please contact us first using the details in section 15 and tell us what happened. We will acknowledge your complaint, look into it and respond to you in writing within a reasonable period.
If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner:
- Website: www.oaic.gov.au
- Phone: 1300 363 992
14. Changes to this policy
We may update this policy from time to time. The current version is always the one published on this page, and the date at the top shows when it was last updated.
15. Contact us
Scott Daniel Feeney trading as Recirc.AI
- ABN: 92 721 361 463
- Address: 163 North Forbes Road, Condobolin NSW 2877
- Email: scott@recirc.ai